Ivory Kapitmoor

TABLE OF CONTENTS

  • 1. The Scope
  • 2. What Personal Data Do We Have on You
  • 3. No Requirement to Disclose Personal Information
  • 4. What Personal Data We Collect
  • 5. Legal Basis and Reasons for Processing of Personal Data
  • 6. Transfer of Personal Data to Third Party
  • 7. Cookies and Services from Third Parties
  • 8. Retention of Personal Data
  • 9. International Transfers
  • 10. Security of Personal Data
  • 11. Hyperlinks to Third Party Websites
  • 12. Modifications to This Policy
  • 13. Your Rights

Privacy Policy

Last updated: 21.07.2026

We (also known as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy is designed to inform you about how we collect and store the information you provide through the website Ivory Kapitmoor (the "Website").

We want you to be well-informed about how your Personal Data is used and processed. We use a range of methods to keep you up to date with relevant information. Where specific details are needed, we'll provide them at the appropriate time. We're also happy to answer any questions you may have regarding any limitations imposed by law.

By using our website, you confirm that you have read and agree to this Privacy Policy. For enquiries: support@ivorykapitmoor.com

1. The Scope

1.1 This policy describes the types of Personal Data the Company collects from individuals, and how it is processed, shared with third parties, secured, and more.

1.2 This Policy applies to information relating to an identified or identifiable natural person. An identifiable natural person is someone who can be directly identified, or identified through a combination of additional information we hold or are reasonably able to access.

1.3 "Processing" under this Policy refers to any activity involving the use or collection of Personal Data, including its management, organisation, and storage.

1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from individuals under 18 years of age. We do not knowingly permit such individuals to use our services. If we become aware that we hold information relating to a child, we will delete it as promptly as possible.

2. What Personal Data Do We Have on You

2.1 When you access our services and channels, or visit our website, we collect Personal Data. We may also request your Personal Data in certain circumstances.

2.2 In other instances, we collect your Personal Data by analysing how our Services and service channels are used, or by receiving your information from our third-party partners.

3. No Requirement to Disclose Personal Information

3.1 You are not obliged to provide Us with any Personal Data. However, in certain circumstances, choosing not to do so may limit Our ability to offer the Services or prevent users from accessing the website.

4. What Personal Data We Collect

4.1 This includes information about your online activity log and traffic data, including:

  • IP address
  • Date of access and time of access
  • Language you used
  • Software crash logs
  • Type of browser used
  • Information regarding the device that you utilised

4.2 The information collected is not personal information and cannot be used to identify you.

4.3 Personal Data we receive from you: any personal data you voluntarily provide to Us when you connect with a third-party online trading platform through Us.

4.4 Personal information you provide directly to third-party platforms to facilitate trading: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing of Personal Data

5.1 Your personal data is processed by the company for the purposes outlined in this section, in accordance with the applicable legal basis.

5.2 The Company requires a legal basis to process your Personal Data. The following legal grounds permit the Company to process Personal Data about you:

  • You have given your consent to the processing of your Personal Data for one or more purposes. This applies when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
  • The Company or a third party may need to process your data to meet legitimate interests — for example, to improve Our Services or to defend legal claims.
  • Processing must meet an obligation of law.

5.3 Contact Us via email for more details on the processing required to protect legitimate interests.

5.4 Below is a list of the reasons and legal grounds on which we may use the information you provide to us:

Scope

Legal Basis

1. To provide your personal information to third parties at your request, in order to gain access to digital trading
If you request it, we may collect your Personal Data to forward it to third-party companies.

You have given your consent to the processing of your Personal Data for one or more reasons.

2. To respond to your requests, questions or concerns
Personal Data is required to help address any questions you may have about the Services.

Processing is necessary to meet the legitimate interests of the Company or a third party.

3. To meet any legal obligation or administrative, judicial, or regulatory requirement, Personal Data is processed in accordance with applicable legal obligations.

To ensure compliance with legal obligations, processing is required.

4. To Enhance Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, crash reports and malfunction data we collect in relation to the Services.

Processing is necessary to fulfil the legitimate interests of the Company or a third party.

5. To stop fraud and misuse of Our Services.

Processing is necessary to serve the legitimate interests of the Company or a third party.

6. To carry out and manage activities that align with the requirements of Our Services
This includes back-office functions, business development, strategic decision-making, oversight mechanisms, and similar activities.

Processing is necessary to fulfil the legitimate interests of the Company or a third party.

7. To conduct analysis, such as statistical analysis
To make decisions on various matters, we use a range of analytical techniques (including statistical methods).

Processing is necessary to serve the legitimate interests of the Company or a third party.

8. To safeguard our assets, rights and interests as well as those of third parties
Personal Data may be processed by us to protect our rights, interests and assets, or those of third parties, in accordance with applicable laws, regulations, agreements, conditions, terms or policies.

Processing is necessary to pursue the legitimate interests of the Company or a third party.

6. Transfer of Personal Data to Third Party

6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, IP address information, and user experience analysis.

6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will pass on the Personal Data you have provided to us to those third-party trading platforms. The use of your Personal Data will be subject to their respective privacy policies. Your Personal Data may be shared with multiple trading platforms.

6.3 The Company may share Personal Data with related entities or business partners. This enables the Company to access the resources needed to enhance and improve the products and services provided to its customers.

6.4 Where necessary to protect the rights of third parties or their assets, the Company may disclose Personal Data to regulatory, local, or other relevant authorities.

6.5 We may also share your Personal Data with potential investors or buyers, or with lenders to the Company or any other company within the group, in the event such a transaction takes place (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation, or bankruptcy of the Company or any other business within the group.

7. Cookies and Services from Third Parties

Third-party services, such as advertising providers and analytics companies, may be used on our website. These companies may also make use of cookies or similar technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits in order to improve your user experience, remember your settings, and personalise the products and services most relevant to you. Cookies are also used for statistical and analytical purposes.

7.3 Some cookies we use are session cookies. These are temporarily downloaded to your device and remain active only until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a period of time after you close your browser. They are used to help the Website recognise you as a returning user and allow you to return to the website.

The type of cookie

Cookies are absolutely necessary

Scope

These cookies are necessary to access the features you've requested and to navigate our website. They are used to deliver the information, products, and services you have asked for.
They are required for your device to download and stream data, allowing you to navigate the website, use its features, and return to pages you've previously visited.

Additional Information

Cookies collect personal data, such as your username and last login date, to confirm you are logged in to the site. They are deleted when you close your web browser (session cookies).

The type of cookie

Functionality Cookies

Scope

Cookies allow us to recognise you each time you visit our site and to save your settings and preferences.

Additional Information

They remain active until their expiry date and are retained even after the browser is closed.

The type of cookie

Cookies for performance

Scope

Cookies are used to collect statistical data on the site's performance and to help improve it. They also allow us to carry out analysis on our website.

Additional Information

Cookies store anonymous data that is not associated with any identifiable natural person. They can be removed when you close your browser. Other cookies have an indefinite validity period.

7.4 Cookies are blocked or removed. To block or remove cookies, you will need to adjust your browser settings. The following links can help you through the process for some of the most commonly used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please be aware that some or all of the Website's functions and features may not work as expected if this occurs.

Online Tracking Notice: This service does not currently support do-not-track signals.

8. Retention of Personal Data

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose for which it was collected, as described in this Policy, or for longer periods as permitted by applicable laws, regulations, policies, and orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you agree, we will continue sharing your data for a further 12 months.

8.3 We regularly review the Personal Data we hold to ensure it is no longer required.

9. International Transfers

9.1 Your personal information may be transferred to other countries (i.e. your personal data may be transmitted to a third country or to international organisations). The Company takes all necessary steps to safeguard the personal data you provide and to ensure that individuals have the ability to exercise their rights and access effective legal remedies.

These protections and safeguards are available to all residents of the EEA (European Economic Area):

  • Transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
  • The transfer is made pursuant to a legally binding and enforceable agreement between public entities or authorities under Article 46(2)(a)
  • The transfer was carried out in accordance with standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR

9.3 The Company can provide information about the security measures used to protect your Personal Data when transferred to third-party countries or international organisations. Send an email to: support@ivorykapitmoor.com

10. Security of Personal Data

10.1 We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or modification.

10.2 We cannot guarantee that the security of your Personal Data will be maintained without error. We are also not liable for any indirect, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorised third-party access, or any other cause beyond our control.

10.3 In the event of legal or other obligations beyond our control, we may be required to disclose your Personal Data to third parties, such as public authorities. In these circumstances, we cannot control how your Personal Data is handled or protected by those third parties.

10.4 Personal Data cannot be transmitted over the internet in a completely secure manner. The Company cannot guarantee the security of any Personal Data you send to Us online.

11. Hyperlinks to Third Party Websites

11.1 The website may contain links to third-party sites and applications. These sites and applications are not under the supervision of the Company. We are not responsible for the collection or processing of Personal Data by these third-party sites or applications. This Policy does not apply to actions taken through such sites or applications.

11.2 When visiting any third-party websites or apps, we recommend that you read their privacy policies before deciding to access or use them. We also suggest that you carefully consider what Personal Data you provide to them.

12. Modifications to This Policy

12.1 This Policy may be updated at any time. If changes are made, we will notify you by posting the revised Policy on our website.

12.2 In addition, when we make significant changes to this Policy, we will attempt to notify you using appropriate methods and will publish an announcement on our website.

12.3 Unless explicitly stated otherwise, any amendments will take effect upon publication of the revised Policy.

13. Your Rights

13.1 You have the right to request that we verify the accuracy of your Personal Data, correct any errors, and delete any Personal Data we no longer require. You may also request that we limit the scope or types of processing applied to your personal information.

13.2 If you are a resident of the EEA, please refer to this page. These rights apply to the personal information you provide as your Personal Data. To exercise any of these rights, please send an email to the address below.

13.3 Access rights The Company is able to verify the accuracy of Personal Data being processed about you. If so, you are entitled to access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. The data will be made available electronically upon request. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request is detrimental to the rights or freedoms of another person, the Company may refuse to comply with the request or limit its ability to fulfil it.

13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You are entitled to request that any incomplete Personal Data relating to you be corrected, taking into account the purpose of processing.

13.5 Right to Erasure The following reasons apply: (a) Personal Data are no longer required for the purpose for which they were collected or processed; (b) You withdraw consent and there is no legal basis to process; (c) You object at any time, based on a reason specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued by Us or by a third party; (e) Personal Data are unlawfully processed; or (f) Personal Data must be removed to meet the company's lawful obligations. This right does not apply where processing is necessary (a) to fulfil an obligation imposed by law that is required to be processed under European Union law or Member State law; or (b) to establish, exercise, or defend legal rights.

13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you may ask the Company to limit how it processes your Personal Data. If you request such a restriction, your Personal Data may only be retained with your consent, or to establish, exercise, or defend legal rights, or to protect the rights of another individual, or where there is a significant public interest reason within the European Union or a Member State.

13.7 Right to data portability If the processing is carried out by an automated system and is based on consent or a contract you are party to, you have the legal right to access and review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure remain unaffected by the exercise of your right to data portability. The right to data portability does not affect the rights or freedoms of any other person.

13.8 Right to challenge You have the right to object at any time to any use of your Personal Data that is based on legitimate interests pursued by the Company or a third party. This right is not limited to profiling based solely on those legitimate interests. If we are able to establish compelling legitimate grounds for processing your Personal Data, we may continue to do so unless you can demonstrate that your rights, freedoms, or interests outweigh those grounds, or that the processing relates to the exercise, establishment, or defence of legal rights. Regarding direct marketing, you have the right to object at any time to the processing of Personal Data concerning you.

13.9 Right to refuse consent You may revoke your consent for Us processing Personal Data about you at any time. This will not affect the legality or lawfulness of any processing that was carried out based on your consent prior to its withdrawal. You are entitled to lodge a complaint with your relevant supervisory authority. You may submit a complaint to a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as outlined in this section 13.

13.10 We will provide you with the requested information in accordance with the rights outlined in section 13 of this agreement within one month of receiving your request. This timeframe may be extended by up to two months if necessary, depending on the nature and volume of requests received. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

13.11 Unless otherwise restricted by the provisions of section 13 of the law, any information you request under your rights in section 13 will be provided free of charge. If a request is unjustified or excessive, particularly where requests are repeated, we may charge a reasonable fee to cover the administrative costs of providing the information or fulfilling the requested action. We may also choose not to act on such requests.

13.12 If we have doubts about the identity of the person who submitted your request, we may ask them to provide reasonable proof of identity.

This Privacy Policy should be read in conjunction with our Term Of Use and Risk Disclosure.

Ivory Kapitmoor 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@ivorykapitmoor.com